Whistleblowing refers to the act of safe and secure reporting of information concerning breaches or potential breaches that occur in a work-related context.

AikGroup (CY) Limited is committed to endorsing a corporate culture based on ethics and integrity, thus fostering an environment in which all stakeholders are encouraged to report any potential breaches of Code of conduct or regulatory requirements.

What is Whistleblowing?

Whistleblowing refers to the act of safe and secure reporting of information concerning breaches or potential breaches that occur in a work-related context, including:

• Criminal acts: corruption, fraud, bribery, money laundering

• Regulatory breaches: financial, banking, legal, or internal rules

• Ethical misconduct: conflicts of interest, abuse of position, code of conduct violations

• Health, safety, and environment: risks to individuals or environmental harm

• Data and consumer protection: breaches of confidentiality, GDPR, or consumer rights

• Reporting irregularities: manipulation of financial records or misleading disclosures

The purpose of whistleblowing is to allow early detection and correction of irregularities, unethical conduct, or unlawful activity in a secure and confidential manner.

Who is considered a Whistleblower?

A whistleblower is any individual who, in the course of their professional activities, reports information about misconduct or a potential breach.

This includes:

• Current and former employees, job applicants, or trainees;

• Members of the management body;

• Contractors, suppliers, and business partners;

• Shareholders

• Any persons working under the supervision and direction of contractors, subcontractors and suppliers.

Reports may be submitted by any of the persons listed above who have reasonable grounds to believe that the information reported is true at the time of reporting and that this information was acquired in a work-related context.

How are reports submitted?

The Group provides secure and confidential internal reporting channels in line with applicable regulations.

Reports may be submitted through one of the following channels:

• By email to: Whistleblowing@aik-group.com

• By post or in person, addressed to the General Compliance Unit Manager - Bulevar Arsenija Čarnojevića 59a, 11070 Novi Beograd

Is submitting a whistleblowing report anonymous or are you required to provide your identity?

Reports may be submitted anonymously.

If the whistleblower chooses to identify themselves, their identity will be kept confidential and disclosed only where required by law or with their explicit consent.

Who handles whistleblowing reports?

Whistleblowing reports are received and managed by the Group’s Authorized person, who has extensive experience in ensuring regulatory compliance, as well as confidential investigations. Only designated and trained persons have access to whistleblowing reports.

Which issues are not suitable for whistleblowing reports

The whistleblowing channel is not intended for:

• Personal employment grievances or interpersonal disputes

• Customer service complaints

• General inquiries unrelated to regulatory or ethical breaches

Can anyone prevent a Whistleblower from filing a report?

Preventing whistleblowing is prohibited.

What is the deadline for submitting a report?

There is no strict deadline, but reports should be submitted as soon as possible after the whistleblower becomes aware of the issue, to allow timely investigation and remediation

Whistleblowing procedure

Upon receipt of a report:

The Authorized person registers the report and confirms receipt within 7 days (unless the report is anonymous).

The Authorized person conducts a preliminary assessment to determine scope and credibility. Where appropriate, an internal investigation is initiated.

Feedback on the outcome is provided to the whistleblower within 3 months (extendable to 6 months in complex cases), in accordance with the Whistleblowing regulation.

Personal data protection

All personal data is processed in accordance with the EU General Data Protection Regulation (GDPR) and Cyprus data protection laws.

Protection of Whistleblowers

The Group strictly prohibits any form of retaliation, discrimination, or adverse treatment against persons who make a report in good faith.

Whistleblowers are protected under Cypriot Law 6(I)/2022 and Directive (EU) 2019/1937, even if the reported information later proves to be unfounded, provided it was reported honestly and with reasonable belief in its truthfulness.

The Group fosters a culture of integrity, openness, and accountability, encouraging all stakeholders to speak up without fear.